Klaine v. Southern Illinois Hospital Services

Illinois Appellate Court
Civil Court
Medical Studies Act
Citation
Case Number: 
2014 IL App (5th) 130356
Decision Date: 
Wednesday, August 6, 2014
District: 
5th Dist.
Division/County: 
Williamson Co.
Holding: 
Affirmed as modified in part and vacated in part; remanded.
Justice: 
SPOMER
Court found hospital in contempt for failing to produce documents to medical malpractice plaintiffs who alleging negligence in gallblader removal procedure, and negligent credentialing of physician. Court properly ordered Hospital to release information about physician's application for staff privileges, as court may have reasonably found that information in application could contain information likely to lead to admissible evidence on Plaintiffs' claims. A privilege does not exist for applications for staff privileges created per Date Collection Act, as Act contains no explicit provision for privilege. Court properly ordered that peer-review consulting company's report as to physician were to be redacted from documents ordered to be disclosed. The fact that information was furnished to peer-review or quality control committees in form of a summary report does not transform the otherwise discoverable information into privileged information. (WELCH and CHAPMAN, concurring.)